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Name of the Case

State of Madhya Pradesh v. Pujari Utthan Avam

Key Takeaways

  • Circulars were issued by the MP government to delete the names of the Pujari from land revenues.
  • A petition was filed against the order of the HC cancelling the circulars.
  • The Court observed that the Pujaris are only responsible to take care of the temples and the lands.
  • The ownership of the temple and properties lie with the deity of the temple.


  • The Madhya Pradesh government had issued circulars under M.P. Land Revenue Code, 1959 for deleting the names of Pujari from revenue records pertaining to temple properties.
  • The circulars were quashed by the M.P. High Court.
  1. Issues Addressed:
  2. Whether the State Government can order the name of the Pujari to be removed from the revenue record and/or the name of a Collector to be inserted as the temple’s management by executive orders.
  3. Whether the Pujari has any ownership rights.

Parties’ Contention

  • The petitioner contended that the temple’s presiding deity is the owner of the land attached to the temple, and the Pujari’s role is limited to performing puja and maintaining the god’s properties.
  • The state claimed that the executive orders were issued to prevent the Pujaris from selling temple property without permission.

Court’s Observation

  • Pujari is not a tenant in cultivation, a government lessee nor an ordinary tenant of the maufi lands, but rather holds such land on behalf of the Aukaf Department for the purpose of management, according to the Pujaris.
  • The Pujari is merely a grantee charged with managing the deity’s property, and the grant may be revoked if the Pujari fails to do the duties assigned to him.
  • The name of the deity must be provided in the ownership column because the deity is the owner of the land as a juristic person.
  • The god also occupies the land, which is carried out by a servant or manager on behalf of the deity and the manager’s name is not necessary to be listed in the occupier column.
  • Since the Collector cannot be a manager of all temples unless it is a temple vested in the State, the name of the Collector as manager cannot be registered in respect of property vested in the god.

Do you think the deity should be the owner or the powers should be vested with the pujaris or the government? Tell us in the comments section below!

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